1
New Requirements for Boat Fuel
and Fuel Systems
IBEX
September 16, 2015
Speakers: Dave Marlow, Brunswick Boat Group,
Dan Ostrosky, Yamaha Motor Corp., Jeff Wasil,
BRP/Evinrude, John McKnight, NMMA
2
Disclaimer
Note: All references citing manufacturers of
marine watercraft, engines and related
equipment in this presentation are for
informative and illustrative purposes only.
Their use in this presentation does not
constitute an endorsement of these
manufacturers or their products by the State
of California or the California Air Resources
Board.
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Purpose of ARB Regulation
California has the worst air quality in the nation
CARB develops regulations to comply with the federal
Clean Air Act requirements
CARB’s new evaporative regulations for boats will fulfill
a legal commitment included in California’s State
Implementation Plan (SIP)
This regulation will help California obtain the emission
reductions needed to attain federal ozone standards
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Who does this Regulation apply to?
• CARB’s new evaporative emissions regulation applies to
all MY 2018 spark-ignition marine watercraft with
permanently installed fuel tanks sold in California
• Marine watercraft that use engines > 40HP must
meet the more stringent CA standards
• Marine watercraft that use engines ≤ 40HP must
meet harmonized existing U.S. EPA standards
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How it will work!
Fuel Hose Certified
by Component Mfg.
Tank Certified
by Component
Mfg.
Canister Certified
by Component
Mfg.
P.R.V. Certified
by Component Mfg.
Certified Components listed
on SIMW Component Web Page
Builder references Certified
Components from ARB Listing
ARB Certifies Watercraft
Using Components EO’s
in lieu of Components Data
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Component Certification
• What is component certification?
Component certification is the certification of
fuel hoses, fuel tanks, carbon canisters and prv
by ARB
Certification means that manufacturers have
demonstrated that their product meets
applicable design and performance
requirements
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Design Based Standards < 30kW (40HP)
All evaporative emission standards and test
procedures have been harmonized with U.S. EPA
Fuel Tank
Permeation
Diurnal
Requirement
(grams/m2/
(grams/m2/day ROG)
day ROG )
(grams/gallon/
day HC)
Fuel Injection
or Equivalent
(grams/hour)
Standards for
MY2018 and
later
15.0
1.5
0.4
None
Test Procedure
40 CFR §1060.515
40 CFR
§1060.5201
40 CFR §1060.525
None
Fuel Hose
Permeation
1
As an alternative, fuel tanks can be certified to 2.5 grams/m 2/day at 40°C
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Design Based Standards > 30kW (40HP) (Trailerable)*
*Applicable to marine watercraft ≤ 26 ft. in length and ≤ 8.5 ft.in width
Fuel Hose
Permeation
(grams
ROG/m2/day)
Fuel Tank
Permeation
(grams
ROG/m2/day)
Diurnal Tank Venting Loss
Requirement
(grams HC/gallon/day)
Canister1
Standards
for MY2018
and
MY2019
10.0
0.70
0.25
Standards
for MY2020
and later
5.02
0.70
0.25
Test
Procedure
TP-1504 or
SAE J1737
TP-15043
Non-Canister
65% reduction
from
uncontrolled
HC emissions
65% reduction
from
uncontrolled
HC emissions
TP-1503
Meet Fuel Injection
Definition or
Equivalent
Performance
Standard
(grams HC/hour)
0.4
0.4
TP-1502
1
Canisters may be certified by design as an option. Canisters must have a
minimum butane working capacity of 3.8 grams/gallon
2 Must be performed at 40°C
3 As an alternative, fuel tanks can be certified to 1.4 grams/m2/day at 40°C
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Pathways to Compliance
CARB’s new regulation has two methods for demonstrating
compliance (13 CCR 2855 (a)):
1. Design-Based – Requires marine watercraft manufacturer to
use specific CARB-certified components for:
• Fuel injection
• Low permeation fuel hoses
• Low permeation fuel tank
• Passively-purged carbon canister or pressure relief valve
2. Performance Alternative – Requires manufacturers
to meet one standard for the complete boat or fuel system,
based on a 24-hour diurnal test (TP-1501, TP1502)
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New Testing Procedures (TP’s)
ARB will implement the following New Test Procedures or “TP’s” for
component Compliance testing:
TP1501 - Hot Soak for Diurnal Emissions for SIMW
TP1502 - Hot Soak for Evaporative Emissions SIMW
TP1503 - Diurnal Venting Emissions Carbon Canister, PRV
TP1504 - Permeation Emissions form Fuel Tanks, Hoses and Caps
TP1505 – Durability and compliance testing for PRV
Most TP’s follow existing Federal Test requirements
What else is different??
• All sample groups must test 5 samples (2 more than current EPA)
• Requirements to include CAD drawings where applicable
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Component Test Limitations
• ARB will require the following as Worst Case: EPA 1060.235 (b) (1)
Fuel Hose - smallest inside diameter
Fuel Tank – smallest volume to surface area ratio
Carbon Canister – canister sized for the largest fuel tank in category
PRV ( pressure relief valve) – meets minimum design requirements and
additional durability testing
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Basic Component Certification Rules
 Must include testing of 5 components samples (Current EPA is 3
samples)
 Application Must be deemed complete by ARB before it can be
processed
 ARB will issue a component Executive order (EO) for each
component
 ARB will update Web site with New EO’s periodically
 Note: Engine Manufacturer has the responsibility for certification
of fuel injection system. (Will be part of Engine Family EO)
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Fuel Hose Certification (case study)
Example:
A fuel hose manufacturer seeks a
component EO for low permeation
fuel hoses with internal diameters
ranging in size from 1/4 to 3/8
inches
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Fuel Hose Certification Case study
 Letter of Intent (on company letterhead) must include:
 Specific request for an EO for the component
 Description of the barrier material and thickness
 Emissions data results from five (5) component samples (in-house or
third-party testing)
 Reference to the test procedure used to generate the data
 Reference to the test temperature and test fuel used generate the data
 Letter signed by authorized company representative
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Case Study “Hose” cont’d
Letter should also include:
 Description of material composition
 General description of the manufacturing process
 Drawing of component (labeled parts and cross-section, general dimension
measurements, intended placement of EO labeling, etc.)
 Installation and maintenance instructions (if applicable)
 Limits for proper functioning (e.g., temp range, ethanol %, bend radius, etc.)
 Warranty statement (ARB Verbatim or Pre Approved language)
 Other pertinent information (e.g., quality control frequency, fluorination level
verification, etc.) Note: Detail QA process
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Case Study “Hose”
cont’d
Hose emissions data from five (5) samples
Declaration of how the test data was generated (Hose was
tested at a constant 23°C with CE10 following TP-1504)
General material description of the hose along with labeled CAD
drawings
Location and mounting instructions ***
Any conditions which might affect the hose’s integrity (maximum
skin temperature, kinking radius, etc.) ***
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Submission
Manufacturer submits package requesting a
component EO, test data, and other required info to:
California Air Resources Board
Monitoring and Laboratory Division
Attn: Division Chief
P.O. Box 2815
Sacramento, CA 95812
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NOW WHAT???
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ARB Processing
 Logging the date of receipt
 Reviewing the application for completeness
 Notifying applicant if not complete (within 30 days)
 Verifying that 5 hose sample data points are below the design criteria of 10
grams/meter2/day
 Drafting a component EO for the hoses
 Mailing the component EO to the manufacturer
 Adding the component EO to SIMW Component Web Page
http://www.arb.ca.gov/msprog/offroad/sore/sorecomponent/sorecomponent.
htm
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Certification Timing
 ARB can take up to 90 days for complete process
 90 day clock does not start until a complete
application is received and verified.
 Be sure all elements of your application are
included and readable to reduce certification
delays.
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Post Certification
 ARB may conduct compliance testing on Components
 Component manufacturer and boat builder will be notified if a
component fails compliance testing
 EO may be revoked
 Penalties may be imposed (Component Mfg.)
 Component EO is valid until revoked
 Any emissions-related change to the component must be
submitted and reviewed by CARB
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Post Certification
Running Changes:
Non emission affected: Part number, Color, labeling etc…
Submit simple explanation to ARB identifying changes so to be added to
ARB EO file
Note: Should be done annually prior to production
Major Design changes, material thickness, type, brand, mfg. process..
Will require new application and EO
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ARB Contact List
Scott Monday – Regulations and Test Procedures
(916) 445-9319, scott.monday@arb.ca.gov
Michele Dunlop – Component Certification
(916) 323-8971, michele.dunlop@arb.ca.gov
Kevin Curley – Boat Certification
(626) 350-6418, kevin.curley@arb.ca.gov
Details about the new evaporative requirements, test procedures, and
application process can be found on CARB’s Recreational Marine
Activities website:
http://www.arb.ca.gov/msprog/offroad/recmarine/recmarine.htm
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Component Certification
?
Thanks for listening , any questions ?
dan_ostrosky@yamaha-motor.com
714-761-7715
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CARB Boat Certification
• What is boat certification?
– Boat builders demonstrate their product meets
evaporative requirements
• Upon completion, a CARB EO is issued to allow sale of
boat into California
– Boat builders certify an evaporative family
• One application per evaporative family
• An evaporative family can cover many models that
utilize same type of components
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Evaporative System Certification Overview
• What needs to be certified?
– All marine watercraft with installed fuel tanks that use
spark- ignition marine engines sold in California must
be certified annually
• Who can certify?
– Engine manufacturers (Honda Marine, Mercury
Marine, Yamaha, etc.), or
– Boat builders (Crestliner, Bayliner, Mastercraft, etc.)
– Fuel System Builders/Integrators
– Dealers
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CARB Boat Certification Process
• How do I certify my boat?
– Plan model(s) design
– Group models into an evaporative family
– Submit application
– Receive Executive Order
– Sell boat in California
• Why is CARB boat evaporative certification required?
– Provides a formal legal document (EO) showing that the boat is
compliant with CARB evaporative requirements
• A boat builder may build the boat at any point in the process, however
the boat must be certified before it is sold in California
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CARB Boat Evaporative Certification Process
Design-Based
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Boat Builder Planning
• Boat builders should plan the design of the
evaporative system in advance
– May have third party design evaporative
system
– If models remain the same as previous year,
boat builders may submit previous
information
• Once a design has been established, the boat
builder can apply for certification
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Boat Builder Responsibilities
• Boat builders demonstrate their evaporative system meets
requirements
– Design fuel system using CARB certified components
– Placement and integration of evaporative components
– Proper installation of complete evaporative system
– Labeling and warranty
– Other requirements
– Obtain CARB EO
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Boat Builder Application Process
• Design-Based Application - Start of Model Year
– Boat builders submit one application for each evaporative
family
– Boat builder may submit an application at any time after
they know the model design
– On the application, reference the component EO
numbers applicable to each evaporative component
used in the evaporative family
– Submit the application electronically to CARB
– CARB reviews application and, if compliant, issues an EO
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Evaporative Family
• What is an evaporative family?
– Evaporative family means a class of evaporative
components used on boats with similar fuel system
characteristics
– Evaporative families have similar fuel hose types, fuel
tank types, carbon canister sizes, etc.
• Characteristics of evaporative families
– Vented control: carbon canister vs. pressure relief valve
– Fuel tank types: metal vs. plastic
– Fuel hose types: U.S. EPA vs. CARB
– Boat size: trailerable vs. nontrailerable
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Evaporative Family
Example – Single Evaporative Family
Fuel System Design
Evaporative Family Type
Fuel Hose Type
A1-15
Fuel Tank Type
Plastic
Vent Type
Carbon Canisters
0.5L
– 0-60 gallons
0.75L – 62-93 gallons 1.0L
– 93-124 gallons
Trailerable or Nontrailerable
Trailerable
• All models that have these characteristics are
considered one evaporative family and need only one
certification application
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Evaporative Family
Example – Two Evaporative Families
Fuel System Design
Fuel Hose Type
Evaporative Family Type
A1-15
Fuel Tank Type
Plastic or Metal
Vent Type
Carbon Canisters
0.5L
– 0-60 gallons
0.75L – 62-93 gallons
Trailerable/Nontrailerable
Trailerable
• Models using plastic tanks will be in one evaporative
family; models using metal tanks will be in a second
family
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Design-Based System Certification
• How is design-based certification useful?
– Allows boat builders to show compliance
without testing the complete evaporative
system in a sealed housing for evaporative
determination enclosure (SHED)
– Reduces costs of testing
– Reduces lead testing time
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Boat Builder Responsibilities after Certification
• Must re-apply for certification each model year
• Notify CARB of changes using running
change process
–Changes to evaporative design
–Model additions
• Boat builder is not responsible for
noncompliant component
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Optional Design-Based Conditional EO Certification Process
• Boat builder submits a compliance letter and
requests a conditional EO
• CARB quickly issues EO within 30 days so boat
builder can sell in CA without delay
• Boat builder must submit full design-based
application within 90 days
• If boat builder does not submit full design-based
application within 90 days, CARB revokes EO
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Boat Label & Warranty
• Labels and warranty statements may be
approved ahead of time
• Approval remains valid for future model years
provided no changes are made
• CARB has provided templates for evaporative
emissions labels and warranty statements
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Boat Certification Application Templates
• Draft application, label, and warranty templates for
design-based boat certification are attached
• Boat Certification workshop anticipated to be held
mid 2016
– Present certification forms and processes
– Solicit industry input and get feedback
• Finalized application templates will be issued after
workshop
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Presentation Outline
Section 1: Background
Section 2: Component Certification Section 3: Boat
Certification Section 4: Industry Cooperation
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Cooperation with NMMA/ABYC to Date
• NMMA has been actively engaged with CARB
– Working with CARB since 2006
– Actively participated in all CARB marine
workshops
– Helped to understand the unique
manufacturing process of the boat
building industry
– Organized face-to-face meeting with ABYC,
industry representatives, and boat builders
– Organized boat builder manufacturing tour
– Helped streamline CARB marine
certification
– Provided information about current
NMMA certification process
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Alternate CARB Evaporative Certification Process
streamlined with NMMA
- - - - Alternate path for NMMA members
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Anticipated Implementation Schedule
Early 2016:
Mid 2016:
Begin TestingBoat Certification
Components
Workshop
2017:
Begin Submitting
Watercraft
Applications
Late 2016:
Begin Submitting
Component
Applications
MY 2018:
SIMW Regulation
Implemented
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Spark-Ignition Marine Watercraft (SIMW) Design-Based Certification Templates
(Applicable to 2018 MY and Later Watercraft)
ARB has developed a streamlined design-based certification process for boat builders to certify
SIMW and receive a California Executive Order (EO). Specifically, boat builders who want to sell
in California should follow one of the following options:
Option 1 - One-step Design-Based Certification Process:
Boat builder (or NMMA acting on their behalf) must submit a full application and receive an EO
before offering boats for sale in California. Please find listed below the documents that boat
builders must submit as part of the certification application:
1. Full Design-Based Certification Application
(See Attachment: “DESIGN-BASED CERTIFICATION APPLICATION”)
2. Sample combined U. S. Coast Guard/NMMA/ARB/EPA emissions label format
template (See Attachment: “SAMPLE CALIFORNIA EVAPORATIVE EMISSIONS LABEL”)
3. Sample California emissions warranty statement template
(See Attachment: “CALIFORNIA EVAPORATIVE EMISSION CONTROL
WARRANTY STATEMENT”)
Option 2 - Two-step Design-Based Conditional EO Certification Process:
Please see attached flow-chart titled “Draft Proposed SIMW Optional Conditional EO Certification
Process” describing the two-step design-based conditional EO certification process. The two main
steps are:
1. Boat builder (or NMMA acting on their behalf) must submit a signed statement of
compliance letter and receive interim approval (a conditional EO, which will be issued
within 30 days of receipt of the compliance letter) before offering boats for sale in
California
(See Attachment: “DESIGN-BASED CONDITIONAL CERTIFICATION COMPLIANCE LETTER”)
2. Boat builder (or NMMA acting on their behalf) must submit a full application (including
all three documents listed above in Option 1) within 90 days of the signed statement
of compliance letter and receive an EO as in the one-step process.
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NOT FINAL
DESIGN-BASED CONDITIONAL CERTIFICATION COMPLIANCE LETTER
(APPLICABLE TO 2018 MY & LATER WATERCRAFT)
Manufacturer’s Letterhead
Date
Chief, Emissions Compliance, Automotive Regulations and Science
Division Air Resources Board
9480 Telstar Avenue, Suite
4 El Monte, California 91731
XYZ Company (the manufacturer’s legal name) hereby requests that its 20XX model year new
spark- ignition marine watercraft be conditionally certified by ARB based on the compliance
statements in this letter and on its commitment to provide any information needed to demonstrate
full compliance with the California emission standards for new spark-ignition marine watercraft.
XYZ Company hereby makes the following statements of compliance regarding the 20XX model
year evaporative certification of all of its spark-ignition marine watercraft models:
1) Conformance with the general standards and test procedure requirements specified in Title
13, Chapter 5, Article 14, sections 2850-2871 of the California Code of Regulations (CCR).
2) Conformance with the labeling (2860), warranty (2861 & 2862), tamper resistance (2856(e)), and
fuel
injection or equivalent performance standard (2855(a)) requirements as required in 13 CCR.
3) Conformance with the Deck Fill Plate Compatibility Standard as required in 13 CCR,
Section 2855(b)(1) and with the California Fuel Compatibility Standard as required in 13
CCR, Section 2855(b)(2).
4) The XYZ Company’s production will consist of the following watercraft types: (Personal Watercraft,
Outboard, Inboard, Sterndrive, Jetboat, Other). The watercraft will be (Trailerable
≤26ft, Nontrailerable >26ft).
5) Production evaporative systems shall be in all material respects the same as those for
which certification is submitted.
6) The completed evaporative certification application demonstrating compliance will be submitted
to ARB within 90 days of the date of this letter.
7) No watercraft will be introduced into commerce in California before the conditional Executive Order
is issued.
XYZ Company will demonstrate compliance with all applicable California evaporative emission
standards and requirements, including submission of a complete certification application, within 90
days of the date of this letter. XYZ Company understands that failure to adequately demonstrate
compliance by the above specified date shall be cause for the Air Resources Board to revoke the
conditional Executive Order, in which event any watercraft introduced into commerce under the
revoked conditional Executive Order shall be deemed uncertified, and which may subject XYZ
Company to enforcement actions. The projected start date for introduction into commerce in California
is MM/DD/YYYY.
If you have any questions, please contact me at xxx-xxxxxxx. Sincerely,
Manufacturer Representative’s Name
Title
Mailing
Address Phone
Number Email
Revised 7/21/15
NOT FINAL
DESIGN-BASED CERTIFICATION APPLICATION
(APPLICABLE TO 2018 MY & LATER WATERCRAFT)
Date
Chief, Emissions Compliance, Automotive Regulations and Science Division Air Resources Board
9480 Telstar Avenue, Suite 4 El Monte, California 91731
Evaporative Family Name: XXXXXXXXXXXX
Application Type:
_ New
Running Change
XYZ Company hereby submits the certification application and makes the following statements of compliance regarding the 20XX
model year certification of its spark-ignition marine watercraft.
1) Conformance with the general standards and requirements as required in Title 13, Chapter 5, Article 14, sections 2850-2871 of
the California Code of Regulations.
2) Conformance with the Deck Fill Plate Compatibility Standard as required in 13 CCR, Section 2855(b)(1) and with the California
Fuel Compatibility Standard as required in 13 CCR, Section 2855(b)(2).
3) Conformance with the labeling and warranty requirements as required in 13 CCR, Sections 2859, 2860, 2861,
and 2862.
4) Conformance with the fuel injection definition or equivalent performance standard and tamper resistance requirements as
required in 13 CCR, Sections 2855(a) and 2856(e), respectively.
5) Production evaporative systems shall be in all material respects the same as those for which certification is granted.
6) Installation will be completed as directed by the component manufacturer and will adhere to the specifications within the referenced
component Executive Order(s).
Fuel Tank Executive Order(s)
List ARB EO number(s)
Manufacturer Contact Contact:
Title: Company: Address:
City, State, Zip Phone No.:
Fax No.: Email:
Fuel Line Executive Order(s)
Carbon Canister/Venting System (Diurnal)
Executive Order(s)
List ARB EO number(s)
List ARB EO
List Fuel Tank Range
number(s)
List ARB EO
List Fuel Tank Range
number(s)
Production Plant Location/Contact Contact:
Title: Company: Address:
City, State, Zip Phone No.:
Fax No.: Email:
Watercraft Type
Watercraft Specifications
Personal Watercraft
Trailerable (≤26ft)
_ Nontrailerable (>26ft)
Outboard
Less than 30kW
Greater than 30kW
Inboard
Evaporative Warranty/Label Approvals Label Approval #: NMCSterndrive
2018-XXXX
Warranty Approval #: NMC-2018-XXXX
If you have any questions, please contact me
at xxx-xxx-xxxx.
Jetboat
Sincerely,
Other: _
Manufacturer Representative’s Name
Confidential Information
Title
a) Projected California sales(units):
b) Projected 50-State Sales (units): _
Page 1 of 2
Revised 7/21/15
c) Introduction into commerce date:
NOT FINAL
SAMPLE CALIFORNIA EVAPORATIVE EMISSIONS LABEL
(COMBINED WITH US EPA, NMMA, AND USCG)
Revised 2/25/15